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FRIEDMAN v. C.I.R.

No. 98-2378.

216 F.3d 537 (2000)

Michael FRIEDMAN, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: June 8, 2000.

Attorney(s) appearing for the Case

J. Timothy Bender (briefed), Joseph P. Alexander (argued and briefed), Roetzel & Andress, Cleveland, Ohio, for Petitioners-Appellants.

Teresa E. McLaughlin (argued), Ann Belanger Durney (briefed), Paula K. Speck (briefed), U.S. Department of Justice, Appellate Section Tax Division, Washington, D.C., for Respondent-Appellee.

Before: BOGGS and NORRIS, Circuit Judges; NUGENT, District Judge.

OPINION

NUGENT, District Judge.

The Commissioner of Internal Revenue (hereinafter "Commissioner") issued notices of tax deficiencies to Michael and Madeline Friedman and Edward and Deborah Rosenthal1 (hereinafter "Taxpayers") for the years 1989 and 1990. The notices stated that Taxpayers were not entitled to a loss in the amount of $5,055,116. As shareholders of an S corporation, Taxpayers made claims for net operating losses...

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